Categories

Author

Year

Publications

10/2019

U.S. Tax Implications of Offshore Trusts

Present lecture on assessing trust structures from a U.S. income tax perspective. RSM US LLP – Internal Private Client Training. October 1, 2019.…

5/2019

The Mechanics and Pitfalls of GILTI and FDII

Severiano Ortiz’s publication, Cushioning the Double-Tax Blow: The Section 962 Election, from September 21, 2018, is cited. Tax Notes. May 20, 2019. Download…

Cross-Border Estate Planning

This panel focuses on provisions of the US tax code relevant to assessing and implementing cross-border estate planning. Points of discussion include identifying the tax status of the taxpayer and…

Analyzing Foreign Trusts

This panel focuses on the application of the US tax laws as they relate to identifying foreign versus domestic trust structures. This panel outlines a roadmap from which to analyze…

12/2018

Foreign Trusts and How to Recognize Them

Present lecture on Identifying foreign trusts and how to tell the difference between a U.S. domestic versus a foreign trust, and how to identify whether such trust is a grantor…

11/2018

Cross-Border Tax Issues Affecting the Private Client Services Client

Our presentation covers the basics of cross-border estate/gift/income tax planning with a focus on identifying tax residency and domicile, domestic versus foreign trusts, international information compliance, and delinquent filing procedures.…

10/2018

A Galley, Head… and Tax Deduction? Tax Savings and Boat Ownership

Tax Benefits, Tax Reform, and Fractional Boat Memberships: This article addresses the intersection of the U.S. tax code as applied to houses, boats, and now fractional boat memberships. These days…

9/2018

Review of International Informational Reporting Forms and Related IRS Compliance

Conduct an internal training for our private client department to teach its tax professionals about the application of the U.S. Income Tax Code and related international informational filings. RSM US…

Cushioning the Double-Tax Blow: The Section 962 Election

The passage of the 2017 Tax Cuts and Jobs Act (TCJA) was heralded as the beginning of a new age in international taxation. Finally, the injustice of the double tax…

8/2018

Application of the U.S. Gift and Estate Tax Code to Cross-border Families

Conduct an internal training for our private client department to teach its tax professionals about the application of the U.S. Estate and Gift Tax Code to non-resident aliens and cross-border…